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A Comity of Error: Analyzing New York's Choice of Law Rules in Stolen Art Cases

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In the multi-billion dollar international art market, whether or not a work of art has "good title" is a critical question that can be answered in different ways, depending on the laws of different international jurisdictions. In the determination of whether title is good, conflict of law analysis, rooted in the principle of comity, is extremely important.

The article addresses why conflict of law analysis is particularly important, and analyzes relevant case law and its potential repercussions on buyers and sellers of artwork overseas.

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